Corporate Governance 
at 
Halley Galt Incorporated 

At Halley Galt Incorporated, our commitment to ethical conduct is the bedrock of our corporate identity. We adhere unwaveringly to a mission that places integrity, transparency, and accountability at the forefront of our operations. Our Ethics Mission Statement guides every decision and action we take, reflecting our dedication to conducting business with the highest standards of honesty, fairness, and responsibility.

Halley Galt Incorporated is steadfast in its commitment to upholding the integrity of financial markets. We strictly prohibit insider trading, recognizing its detrimental impact on market fairness and trust. Our comprehensive Insider Trading Policy outlines clear guidelines for all employees, emphasizing the importance of respecting confidential information and preventing any misuse for personal gain. By fostering a culture of compliance, we ensure the continued trust of our stakeholders and the broader financial community.

Halley Galt Incorporated maintains the highest standards of accounting integrity. Our financial practices adhere to rigorous standards, ensuring accuracy, transparency, and compliance with applicable regulations. We employ qualified professionals dedicated to upholding the principles of fair financial reporting. Through meticulous record-keeping, regular audits, and a commitment to accountability, we ensure the reliability of our financial information. Our steadfast focus on sound accounting principles underscores our commitment to providing stakeholders with a clear and trustworthy financial picture.

Our Corporate Code of Ethics serves as a compass for the conduct of Halley Galt Incorporated and its subsidiaries. Rooted in principles of integrity, respect, and social responsibility, our code establishes the expectations and standards that govern our interactions with employees, customers, partners, and the communities we serve. By embodying these values, we cultivate a corporate culture that fosters trust, encourages innovation, and reflects our commitment to being a responsible and ethical global citizen.

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Halley Galt Incorporated and its subsidiaries stand united in their pledge to uphold these principles, fostering a corporate governance framework that not only meets regulatory requirements but surpasses them, ensuring sustained success built on a foundation of ethical excellence.